FDPIR Management Evaluations

PurposeProcessCommon Findings

NAFDPIR 2015

New Program Integrity and Monitoring Branch

Monitor MEs for trends: Need for additional training Technical assistance Change or develop policies or

procedures

Purpose

Ensure compliance with Federal regulations and other guidance materials

Identify needs for technical assistance

Take back best practices to share

Format

• Most MEs are conducted on-site, with a desk review of some documents and/or case files prior to the on-site portion of the review

• Some MEs may be conducted as “focused” MEs and consist of an off-site review of case files or other documentation.

Timeline

> 30 days before on-site review: - Notify State Agency/ITO of ME - Requested documents/questionnaire due

to RO On-site review

- Typically 3-5 days 60 days after on-site review or exit

conference:- Report due to SA/ITO

60 days after ITO/SA receives ME report:- SA/ITO’s initial corrective action response

due to RO

Timeline (cont.)

Corrective Action negotiation continues until RO accepts Corrective Action Plan (CAP)- When CAP is accepted, RO must also verify that

the actions have taken place. ME will remain open/in progress until corrective actions have been verified.

RO sends closure letter

Process: Before the On-Site Review

• Negotiate schedule for review• Send official notification letter• Request any documents needed for pre-on-

site review, which may include:- Plan of Operation- Case Files- Self-Assessment- Questionnaire

Process: During the On-Site Review

• Entrance Conference• Interview:

- Program director - Financial/grants management staff- Other staff as needed (i.e.: warehouse,

certifiers)• Inspect:

- Condition of the warehouse- Temperature logs- Food storage organization- Accessibility

Process: During the On-Site Review (cont.)

• Review: - Case files - Equipment list- Training materials and logs

• Observe (when possible): - Tailgate distribution - Certification appointments- Inventory procedures

• Exit Conference- Discussion on potential findings and observations

How to Prepare

The best way to prepare for an ME is to complete an annual self-assessment and ongoing monitoring of your program

Use the FNS FDPIR ME module to anticipate what reviewers look for and request: http://www.fns.usda.gov/fdpir-management-evaluation-module

Tips

Invite all interested parties to the entrance conference

Share any cultural tips or etiquette that you want reviewers to know

Have documents organized and ready for review

Hold a brief meeting to introduce reviewers to help put your staff at ease

Be prepared to share best practices and ideas

ME Report – What to Expect

Executive summary Noteworthy initiatives: May include

best practices that exceed regulatory requirements.

Findings: Identification of non-compliance with program regulations, policies, or procedures.

Required Corrective Actions: Actions that must be taken to change or improve operational effectiveness and correct non-compliance.

ME Report – What to Expect (cont.)

Observations: Identification of a weakness involving management practices or unregulated activity.

Suggestions: Actions that address observations made in the ME- may not be required under the regulations but should be taken to improve program operations and management.

Common ME Findings – Plan of Operation

The Plan of Operation must be in compliance with FNS regulations. The program must be in compliance with its Plan of Operation.

Not up-to-date with FNS policies that have changed

Does not reflect current program operations

Common ME Findings – Staffing

There are limitations to the type of staff who may perform certification functions.

Volunteers used inappropriately

Staff who work on multiple programs or non-FDPIR activities do not correctly allocate time for budget purposes

Common ME Findings – Records & Reports

• Late reports

• Records not kept for required 3 year time period/inaccessible

• Equipment list not kept or missing required information

Common ME Findings – Inventory Control

• Outdated product in inventory

• FNS-152 reports show frequent losses and gains

• Food losses not adequately tracked

Common ME Findings - Warehousing

Warehouse must be clean, temperature-controlled, and protect against the elements, infestation, and theft.

• USDA Foods were improperly stored with no space separation; with non-food items; or with non-USDA Foods

• Temperature logs were not being kept.

• Sanitation/health inspections of the warehouse are not up-to-date.

Common ME Findings – Eligibility

• Case files do not contain adequate documentation

• Income deductions are applied incorrectly

• Two-year certification periods incorrectly assigned

• Common errors in case files

• Conversion factors or earned income deduction incorrectly applied or not used when necessary

Common ME Findings – Nutrition Education & Outreach

• Public notification system (e.g., brochures, bulletins, leaflets, letters, newspapers, etc.) to inform potentially eligible persons, is not effective/inadequate

• No records of nutrition education activities held at the ITO warehouse/tailgates for FDPIR recipients

• Nutrition Education funds spent on inappropriate items

Common ME Findings – Civil Rights

• Non-discrimination statement is incorrect or missing on program forms

• All staff do not complete annual CR training

Common ME Findings – Training

Programs must have a continuing training program for all staff, including volunteers.

• Program does not assess training needs / staff do not receive training on all required elements

Common ME Findings – Program Monitoring

Programs must monitor and review their operations and local agency operations at least annually.

• Annual self-monitoring review is not conducted

• Annual self-monitoring review does not include all required elements

PROGRAM MONITORING & SELF-ASSESSMENT

NAFDPIR 2015

Program Monitoring

Program Monitoring Conducting an Annual Review / Self-

Assessment Annual and Periodic Case File Review

Annual Review – Requirements

Programs are required to conduct an annual self assessment that includes:

Certification Determination of food preferences Distribution Civil Rights compliance Fair hearing procedures Warehousing and inventory Timeliness and accuracy of reports Training

Annual Review – Tools & Documentation

Programs should develop their own tools for self assessment and/or share tools that other FDPIRs have developed.

The completed annual review, plus the corrective action plan, must be documented.

Discussion on Annual Review

• When do you do it? / How often?• Who does it?• What tools do you use?• What common issues do you find?• What corrective actions do you take?

Annual & Ongoing Case File Review

Case file review must be a part of your annual review.

Additionally, periodic case file reviews are a best practice to ensure program integrity and to identify staff training needs.

Discussion on Case File Review

• When do you do it? / How often?• Who does it?• What tools do you use?• What common issues do you find?• What corrective actions do you take?